OK - I've read myself into confusion, Here's my scenario... What if an employee that is jointly employed by a bank and its affiliate financial subsidiary has access to bank file folders that contain in part nonpublic personal information NOT related to the bank's own experiences (credit report). The joint employee is accessing the bank file to determine what product the bank subsidiary could offer a bank customer and may or may not be using the credit report. IMO the bank is required to give its customers a FCRA affiliate opt out notice. Would this be a somewhat correct interpretation of the FCRA affiliate opt-out requirements?

You're darn tootin'!

If, ABC Bank had a "Divison Of" Bank called XYZ Bank would this apply?

If the Charter # for XYZ Bank and ABC Bank are the same, they are the same company - not affiliates. The rule does not apply to "named branches."